OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

May 24, 1995

Mr. Blair M. Brewster
Box 25
West Port Bay Road
Wolcott, NY 14590-0025

Dear Mr. Brewster:

This is in response to your July 30, 1994, letter requesting information and clarification concerning the Electric Power Generation, Transmission, and Distribution standard, 29 CFR 1910.269. Please accept our apology for the delay in responding.

As you requested in your letter, a copy of the stay on the enforcement of some of the requirements contained in the aforementioned electric power generation standard published in the Federal Register (FR), Volume 59, Number 125, on Thursday, June 30, 1994, is enclosed for your use. Please note that the stay was in effect until November 1, 1994. As of November 1, the electric power generation standard has been and continues to be fully in effect except that paragraph (a)(2) on training became effective January 31, 1995, and paragraph (v)(11)(xii) of the 1910.269 standard concerning coal-handling operations which may produce a combustible or flammable atmosphere was stayed until February 1, 1996.

Under 1910.147(c)(5)(ii)(C)(2) and 1910.269(d)(3)(ii)(D), a tagout device and its means of attachment must be substantial enough to prevent inadvertent or accidental removal. Also under these paragraphs, the means of attachment, not the tagout device itself, must be of a non-reusable type, attachable by hand, self-locking, and non-releasable with a breaking strength of no less than 50 pounds (22.68 kg) and must have the general design and basic characteristics of being at least equivalent to a one-piece, all environment-tolerant nylon cable tie.

Under 1910.147(c)(5)(ii)(D) and 1910.269(d)(3)(ii)(E), a lockout and a tagout device must be identifiable, that is, indicate the identity of the employee applying the device. The "lockout tag" described in your letter could be read as an informational tag accompanying a lockout device, for example, as required by the lock and tag provisions of 1910.333(b)(1)(iii). Such informational tags are not required specifically by 1910.269(d).

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact Mr. Ronald Davies of my staff, telephone 202-219-0831, extension 110.


John B. Miles, Jr., Director
Directorate of Compliance Programs